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www.fueloilnews.com | FUEL OIL NEWS | MAY 2016 25 FON: If you look at our end of the indus- try--bulk plants and smaller product terminals--are there any regulatory issues or legislative issues today that are of interest? GEYER: The EPA with its Spill Prevention, Control and Countermeasure plan--they were modifying that like every two years. That's kind of settled down now. We have an inspection standard, SP001, that's been hugely successful. EPA references it a lot, as it refers tank own- ers to what they can use to verify the integrity of their tanks as required by SPCC. They do SP001 inspections. FON: How is secondary containment playing out on the steel side of the tank industry? GEYER: Some of our underground standards probably became a little more obsolete when all the secondary containment requirements were put into effect. Today, jacketed underground tanks are the primary tank of interest for steel tanks for petroleum marketers. Aboveground, our niche has been with secondary containment tanks. It's pretty significant how many aboveground tanks now are all secondary con- tained. What drove that were the EPA regulations and the fire codes because what they did was they said if you have a double wall tank with overfill protection, prevention—you don't have to have a dyke. That was a huge maintenance issue for tank owners. Not to have to deal with that oily water and a dyke. They accept double wall tanks up to 50,000 gallons without hav- ing to have a dyke as long as you have a means to prevent overfill. The fire codes go a little bit further than that, but I think that made it a lot more feasible and made aboveground tanks a lot more popular for the private sector. When I say private sector, again, I'm talking about fleets. Probably some of your bulk plant owners now do double bottoms with their vertical tanks. That ties into these inspections that I talked about. If you have a double-wall tank and you have to verify integrity, which is what SPCC requires, all you have to do is do a little test of that interspace to show both walls are tight and you're done. If you have a vertical tank with the floor on clay or native soil you're going to have to have someone climb inside that tank and take wall thickness readings of the metal, and then you have safety issues. FON: What are your thoughts on the corrosion issue that con- tinues to be discussed with ultra-low sulfur diesel and metal equipment in tanks? What's so odd is the lack of clear causality from a manufacturer, or region or other specific factors. GEYER: The whole industry talks about water being bad [for] a tank. Ethanol kind of sucks up the water, and if it sucks up too much it phases out. That's pretty well known. Biodiesel tends to suck it up a little bit, too. One of the theories was that switch loading, where you have the carrier truck delivering E10 and then is goes back and fills up with ULSD, that some of the ethanol traces get in the bottom of a diesel tank. The hypothesis is acetic acid is a result of a bug called ace- tobacterium eating the ethanol and using the water as its energy and causing acetic acid to form and then vaporize. We're not seeing that in E10 tanks. That's the thing. I mean, in the Chicago area they've had ethanol here for 30 years and the steel tanks have always been spotlessly clean from the ethanol. And just about everything we hear about is from underground tanks. Why aren't we hearing it from aboveground? It's kind of got people scratching their heads. FON: I know the initial study where that theory came out. My issue was that it was too limited given the potential ramifications. GEYER: You can't take that too lightly at all. I think the goal is to do more laboratory tests to understand what the phenomenon is a little better and hopefully find some solutions to it. I know you can have up to what—5% biodiesel in ultra-low-sulfur diesel without even having to mark it. Some people throw that out, but I don't think that's been proven to be a cause either. We work pretty close with the National Biodiesel Board. We try to keep each other aware of what some of the issues are. So, we shall see. It's still an unknown. It's still hard to pin that one down. l F O N STEEL TANK INSTITUTE STEEL TANK INSTITUTE STEEL TANK INSTITUTE STi's 1916 organizational letter.